In 2015, the IRS added new series of compliance questions to the Form 5500/5500-SF annual retirement plan returns, however they are now recommending that plan sponsors skip these questions due to not being approved by the Office of Management and Budget. Specifically, the following questions are recommended to be skipped on the 2015 form 5500:
- Preparer information is not required to be listed on Page 1.
Schedules H and I
- 4(o) – Did the plan trust incur unrelated business taxable income?
- 4(p) – Were in-service distributions made during the plan year?
- 6(c-d) – Trust information
Schedule R– All of Part VII: IRS Compliance Questions
- Is the plan a 401(k) plan?
- How does the 401(k) plan satisfy the nondiscrimination requirements for employee deferrals and employer matching contributions?
- If the Average Deferral Percentage (ADP) test or Average Contribution Percentage (ACP) test is used, did the plan perform testing using the “current year testing method” for non-highly compensated employees?
- Did the plan use the ratio percentage test or the average benefit test to satisfy the coverage requirements under Section 410(b)?
- Does the plan satisfy the coverage and nondiscrimination tests by combining this plan with any other plans under the permissive aggregation rules?
- Has the plan been timely amended for all required tax law changes?
- Provide the date of the last plan amendment/restatement for the required tax law changes.
- Provide the date of the last favorable determination letter received.
- Is the plan maintained in a U.S. territory?
More information from the IRS, including specific questions to skip on the form 5500-SF can be found at the IRS website.
While the forms will not be updated to remove these questions for this year, Plan Sponsors should consider leaving them blank as the IRS recommends.
If you have any questions regarding the new questions in the 2015 Forms 5500, Barnes Dennig wants to help. For additional information, please call us at (513) 241-8313 or contact us online here. We look forward to speaking with you soon!